NRC-96-0060, Submits Special Rept to Describe Circumstances Involving Use of Provision Contained in TS Action 3.7.2.b.1.Util Believes Preparation of Rept Places Undue Administrative Burden & No Future Repts of Nature Will Be Submitted

Submits Special Rept to Describe Circumstances Involving Use of Provision Contained in TS Action 3.7.2.b.1.Util Believes Preparation of Rept Places Undue Administrative Burden & No Future Repts of Nature Will Be Submitted

ML20115A854
Person / Time
Site:	Fermi
Issue date:	07/01/1996
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-96-0060, CON-NRC-96-60 NUDOCS 9607090043
Download: ML20115A854 (2)

Text

,- - . . - - - -

-n . , -. n. . . - . . _ . . .n..- ~ . -

9 l j> .,7 <

s. ,. Dougt s R. Ripsen ,;

I- * '*-

Senxer Vice President  ;

Nuclear Generation , i Fermt t .

6400 North Dinee Rghway Newport, M.cNgan 48166

.(313)666-5249 July.1,1996 i NRC-96-0060 ,

I U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D. C. 20555 i o

References:

1) Fermi 2 NRC Dcdket No. 50-341 NRC License No. NPF-43 I i

2) Detroit Edison letter to NRC, l NRC-91-0150, dated November 11,1991, " Commitments  !

Concerning Control Room Emergency Filtration System"  !

3) NRC letter to Detroit Edison, dated April 22,1992, " Fermi 2- l Amendment No. 81 to Facility Operating License No. NPF-43 j (TAC No. M77679)"  !

Subject:

Use of a Provision Contained in Technical Soccification 3.7.2. l

" Control Room Emergency Filtration System"  :

As described in Reference 2, this special report is being submitted to describe the i circumstances involving the use of a provision contained in Technical

. Specifiestion (TS) Action 3.7.2.b.l. This specification states that if both divisions i of a redundant subsystem of the Control Center Heating, Ventilation and Air Conditioning (CCHVAC) system become inoperable when in Operational '

Condition 1,2, or 3, then the plant must be brought to hot shutdown within 6 .

hours unless a provision is invoked that allows this action to be delayed for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to perform specified surveillances. s

}  !

At 0615 on May 28,1996 Division 2 of the CCHVAC system was declared [

inoperable for scheduled maintenance. During the performance of this 4g7 l

. maintenance a damper in the ductwork common to both divisions was identi'ied ,

0000?9 to need repair. Due to this maintenance, Division 1 CCHVAC system operation f in the recirculation mode was greater than anticipated, thus requiring a charcoal l' sample to be taken during power operation. Usually this sample is taken during

- an outage. l t

'AAer accumulating 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal 'adsorber operation, a charcoal sample is  !

required to be taken by TS Surveillance Requirement 4.7.2.d. Since cumulative l

. operation in the recirculation mode was approaching the 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />, at 2000 on 9607090043 960701 I PDR .ADOCK'05000341 P PDR3 - _ _ _ _ _ _ _ _ _ _ _ _ _

. . . - . _ _ _ ~ ._ __ _ . . _ _ _ . _ _ _ __ ._ _ ._._ _ _ _ _ _ _ . -

i s'

s a 1 , July 1,1996 -,

< * ~ *'

NRC-96-0060'  !

~  ; Page 2. i i j r June 1,1996 Division 1 of the CCHVAC system was shut down to take the i required sample. Both divisions of the CCHVAC system were inoperable while carbon filter samples were being obtained per Surveillance Requirement 4.7.2.d. l Difficulties e.ncountered while performing this Surveillance Requirement

- prolonged the completion of this surveillance.  !

1

At 0436 on June 2,1996, a power reduction was initiated in accordance with TS

- Action 3.7.2.b.1 which requires achieving hot shutdown within six hours. At -

0748 the CCHVAC system surveillance was completed satisfactorily and the six '

. hour to hot shutdown Limiting Condition for Operation (LCO) which would have l expired at 0800, was exited. The seven day LCO for the Division 2 CCHVAC

! - system was resumed in accordance with TS Action 3.7.2.b.2. i I  !

I The commitment for this special report was made in Reference 2 in 1991 and was

mentioned in Reference 3. In Reference 2 Detroit Edison stated thn this .

provision for a six hour in TS Action 3.7.2.b.1 was expected to be used )

i infrequently. Furthermore, Detroit Edison committed to providir.g specific

notification by special report whenever this provision was used. Since NRC

approval of the amendment in 1992, this is the first special report of this type that j- has been required.' Thus, it has been demonstrated that the use of this provision for the CCHVAC system is uncommon.

Preparing this special report places an undue administrative burden with no

. corresponding safety benefit to the plant or to system reliability. Detroit Edison has performed an evaluation of this commitment based on guidelines published by the Nuclear Energy Institute (NEI). This evaluation has determined that removing this commitment will have no impact on safety. Therefore, Detroit Edison intends to change this commitment and not submit Sture reports of this nature.

For further information please contact Mari Jaworsky, Compliance Engineer, at 313-586-1427.

Sincerely, cc: M. J. Jordan A. J. Kugler ,

H. J. Miller I A. Vegel

' Region III

. --